112(r)/Air Enforcement: U.S. Environmental Protection Agency and Santa Ana, California Chemical Supplier Enter into Expedited Settlement Agreement

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (“EPA”) and Gallade Chemical, Inc. (“GCI”) entered into a July 11th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the regulations implementing Section 112(r)(7) of the Clean Air Act. See Docket No. CAA(112r)-09-2025-0073.

GCI is a chemical supplier in Santa Ana, California.

The ESA states that the Santa Ana facility failed to:

  • Maintain documentation of a description of the vessel or pipeline and substance selected as worst case, assumptions and parameters used, and the rationale for selection on the off-site consequence analysis.
  • Maintain documentation of the estimated release quantity, release rate and release duration on the off-site consequence analysis.
  • Maintain documentation of the methodology used to determine distance to endpoints on the off-site consequence analysis.
  • Maintain documentation of data used to estimate the population and environmental receptors potentially affected in the Hydrogen Fluoride Worst-Case Scenario.
  • Ensure and document that the process is designed in compliance with recognized and generally accepted good engineering practices.
  • Submit updated emergency contact information within 30 days of a change in the emergency contact.

GCI neither admits nor denies the factual allegations contained in the ESA.

A civil penalty of $3,480.00 is assessed.

A copy of the ESA can bed downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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